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Yours truly, Olli Laurikainen Section Manager for Division Director International & Trusts Division Income Tax Rulings Directorate Policy and Planning Branch ...

Murphy Section Manager for Division Director International & Trusts Division Income Tax Rulings Directorate Policy and Planning Branch ...

., Manager for Director International & Trusts Division Income Tax Rulings Directorate ...

Murphy Section Manager for Division Director International & Trusts Division Income Tax Rulings Directorate Policy and Planning Branch ...

Manager for Director International & Trusts Division Income Tax Rulings Directorate ...

., Manager for Director International & Trusts Division Income Tax Rulings Directorate ...

Subsection 73(3) states, in part, that "... the property was, before the transfer, used principally in the business of farming... ...

" Application of Section 143.1" of the Legal Opinion. Paragraph 143.1(1)(a) provides that where a NSO that is a registered Canadian amateur athletic association ("RCAAA") receives an amount for the benefit of an individual under an arrangement made under rules of an ISF that require amounts to be held, controlled and administered by the NSO in order to preserve the eligibility of the individual to compete in a sporting event sanctioned by the federation, an inter vivos trust (an Amateur Athlete Trust) is deemed to be created on the day that is the later of the day on which the first such amount is received by the NSO, and January 1, 1992, and to exist continuously thereafter until subsection 143.1(3) or (4) applies in respect of the trust. ...

Murphy Section Manager for Division Director International & Trusts Division Income Tax Rulings Directorate Policy and Planning Branch ...

It has approximately XXXXXXXXXX % of its workforce at customer sites in Quebec and less than XXXXXXXXXX% of its workforce in provinces other than Quebec and Ontario. ...